THE WALL GROUP - PRIVACY POLICY

Privacy Policy

Effective Date: November 13 , 2023

WME FASHION PRIVACY POLICY

This Privacy Policy describes how we use the data (which may include your personal information) we collect from you through our digital properties (“Site”), when you buy merchandise from us online, when you view or interact with WME FASHION content on our online channels, when you attend our events in person, when you use any of our mobile or web applications, when you provide us with a portfolio or profile, and when you otherwise interact with WME FASHION, including our social media, marketing, contests, sweepstakes, and surveys (collectively our “Services”).

Please read this Privacy Policy carefully to understand how we handle your information.

Who we are

How we collect information about you

Information we collect and how we use it

Disclosure of personal information

Events

Marketing and advertising

Social sharing features

Cookies

Do not track

Storage and transfer of information

Children

Privacy rights

Opting out of the sale or sharing of your personal information

Notice to California residents

Security

Links to third party websites

Updates

Contact

Who We Are

WME Fashion operates under IMG Worldwide, LLC.

WME Fashion is the world’s preeminent cultivator of talent, curator of experiences, and creator of brand partnerships across the fashion and beauty ecosystem. Our robust portfolio includes Art + Commerce, IMG Models, IMG Fashion Events and Properties, and The Wall Group which spans talent representation, brand partnerships, event ownership and production, original content creation, and consulting services. WME Fashion offers a complete solution tailored to serve the ever-evolving global fashion industry. We are also part of Endeavor and may share data with its affiliated entities (“Endeavor”).

Like any company, we use a variety of third party businesses and partners to market and provide our Services to you. Some of those companies are part of Endeavor and some are third parties that we partner with or support our operations so we can provide the best experience to you.

How We Collect Information About You

Directly From You

You may provide us with personal information in a number of ways, such as when you:

  • Provide information to us via our websites, applications, and other digital channels by signing up, creating accounts (including using social media login), filling out forms, commenting, or otherwise engaging with our online Services
  • Communicate with us by e-mail or phone
  • Subscribe to e-mails and/or newsletters
  • Report a problem or request support for any of our Services
  • Buy merchandise from us online
  • Interact with our social media accounts
  • Participate in our contests, promotions, sweepstakes or surveys
  • Subscribe to our content online including using any of our online social media channels, official video or streaming partners
  • Apply for an employment opportunity or internship through an approved channel

Information We Collect From and On Behalf of Our Clients

In the context of providing professional services to our clients, we may also collect and process personal information voluntarily supplied by our clients or third parties. When we collect personal information directly from individuals, we will ensure that the collection is performed lawfully with the appropriate notice and consent of the individual or with the requisite lawful basis on behalf of the client.

Information We Collect From Other Sources

We work closely with third parties (for example, technical service providers, promotions companies, advertising networks, analytics providers, and search information providers) and may receive information about you from them. Depending on the relationship and activity, they will provide us with certain information that will help us understand how you interact with WME FASHION Services so we can tailor our marketing and provide better, more personalized Services to you. In some cases, third parties also provide us with information that helps us keep track of transactions, address technical or logistical issues, prevent fraud, or keep our community safe from security threats.

We may also receive and display information and content which you make publicly available on your social media account when you post using one of our promoted hashtags or interact with any of our content.

Information We Collect and How We Use It

Categories of personal information collected

Categories of sources from which personal information is collected

Business or commercial purposes for collection, use, and sharing

Categories of third parties with whom some or all of the personal may be shared

Personal and online identifiers (such as first and last name, email address, phone number, usernames, or unique online identifiers)

Directly from you
Marketing partners

To provide and improve the Services
Personalization of the Services
Customer support
Marketing and targeted advertising
Security and fraud prevention

Customer service partners
Marketing sponsors and partners
Ad networks
E-Commerce vendors

Analytics services

Financial Account Information (such as credit card numbers, bank account information, Paypal account information)

Directly from you
Payment providers
E-Commerce vendors

To provide the Services
To sell you merchandise or
Endeavor content

E-Commerce vendors
Payment providers
Fraud and cybersecurity companies
Endeavor

Customer Profile Information (such as race, nationality, gender, age range, general physical measurements, income range, ad demographics)

Directly from you
Marketing partners
Ad networks
Third party data providers

To provide and improve the Services
Personalization of the Services


Analytics services
Ad networks
Technology service providers

Transactional Information

Directly from you
E-Commerce vendors

To provide and improve the Services
Customer support
analytics
Research and Development


Analytics services
Technology service providers
E-Commerce vendors

Communications with you (such as customer support messages, emails, social media posts)

Directly from you
Customer support partners

To provide and improve the Services
Customer support


Analytics services
Technology service Providers
E-Commerce vendors
Customer service partners

Online Activity Information (such as browsing history, search history, video viewing history, and other interactions with a website, email, application, or advertisement)

Directly from you
Cookies and similar technologies
Marketing partners
Ad networks
Third party data providers

To provide and improve the Services
Personalization of the Services
Direct marketing
Targeted advertising

Endeavor
Technology service providers
Analytics services
Ad networks

Non-Precise Geolocation information (such as zip or area code, state, country)

Directly from you
Cookies and similar technologies Marketing sponsors
Technology service providers
Ad networks

To provide and improve the Services to you
Personalization of the Services
Fraud and cybersecurity
Direct marketing
Targeted advertising

Endeavor affiliates
Ad networks
Technology service providers
Marketing sponsors

Sensory information (such as audio, electronic, visual, or similar information)

Directly from you (such as when you interact with certain apps at our events)
Technology service providers (such as apps and third party analytics platforms activating services at our events)

To provide and improve the Services
Personalization of the services
Enhancing live event experiences
Research and development

Endeavor
Technology services providers

Inferences drawn from the above information about your predicted characteristics and preferences

Endeavor
Third party data providers
Marketing sponsors

To provide and improve the Services
Personalization of the Services
Direct marketing
Targeted advertising
Analytics

Endeavor
Ad networks
Marketing sponsors
Technology service providers
Analytics services

Other information about you that is linked to the personal information above

Directly from you
Endeavor
Third party data providers
Marketing sponsors.

To provide and improve the Services
Personalization of the Services

Endeavor
Ad networks
Marketing sponsors

We may also use the information we have about you as necessary if we believe there has been a breach of the Terms of Use or the rights of any third party, or to comply with legal and regulatory requirements.

We combine information we receive from other sources with information you give to us and information we collect about you. We use this combined information for the purposes set out above.

Disclosure of Personal Information

We share your data with third parties, including event sponsors and other Endeavor affiliates, and the other categories of partners as listed above. Some of these disclosures of data may constitute a sale of data under some data privacy laws. Accordingly, we offer the option for you to opt out of the sale of your personal information, as further set forth below.

We may share your personal information with Endeavor and with selected third parties including:

  • business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you in order to provide you with a product or service;
  • business partners, suppliers and sub-contractors to provide you with information about promotions and offers;
  • advertisers, advertising networks and social networks that require the data to select and serve relevant advertisements to you and, in some cases, to others. For more information on how we use personal information for targeted advertising, see below; and
  • analytics and search engine providers that assist us in the improvement and optimization of the Service.

We may disclose your personal information to third parties:

  • If we enter into negotiations to buy, sell, or merge with any business or assets, or if we enter into bankruptcy, reorganization, or receivership, in which case we may disclose your personal information to the prospective or eventual seller or buyer of such business or assets;
  • if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in the event of an emergency, or in order to enforce or apply our Terms of Use and other agreements, or to protect the rights, property, or safety of WME FASHION, Endeavor, our customers, clients or others; and
  • to any other third party not covered in this policy with your prior consent.

Events

WME FASHION hosts events around the world. Some of these events are owned by WME FASHION or an Endeavor affiliate, others are produced by us working with one or more partners, and some are owned by one or more of our partners. Where an event includes a named sponsor, WME FASHION or its affiliate shares some marketing and other information about you with that sponsor so that you can attend or participate in the events. When we are managing an event that is owned by someone else, your data may be collected and used by us to host the event and to market other Endeavor content to you, and we will also share that data with the owner of the event.

Marketing and Advertising

Targeted Advertising

We use your personal information to tailor our marketing and advertising efforts. To do this, we provide your information to third party advertising networks (such as Google Doubleclick) and social media companies (such as Facebook). When we provide data to agencies, ad networks, and other parties for targeted advertising, we do not provide them with your name, financial information, or any sensitive information (such as a government ID or date of birth, if we have collected that). We use online identifiers such as email, cookie IDs, and device identifiers to help us provide targeted advertising to you and others like you. We may also use aggregate information to help advertisers reach the kind of audience they want to target. We may make use of the personal information we have collected from you to enable us to display advertisements to target audiences.

To opt out of targeted advertising, you may use the following links provided by third parties that manage opt outs for some ad networks:

http://preferences-mgr.truste.com,
http://www.networkadvertising.org/managing/opt_out.asp
http://www.aboutads.info/
https://policies.google.com/privacy/partners

WME FASHION is not responsible for the effectiveness of, or compliance with, any third parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

Email Marketing

We also add you to our mailing lists for email communications from WME FASHION and our partners, including Endeavor, when you sign up for our mailing lists, purchase a ticket or our merchandise, or subscribe to our content online. If you provide us with your email address to receive communications, you can opt out at any time by using the unsubscribe links at the bottom of our emails.

Mobile Notifications

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

Social Sharing

You may be able to use social sharing features and other integrated tools on the Site such as the Facebook “Like” button. These features and tools may permit you to share actions you take on our Service with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the service that provides the social sharing feature. Please remember, though, that use of the information you share on social media sites will be governed by the privacy policies of the social media provider, and we are not responsible for how they treat the information.

Cookies and Technical Data

This Site uses cookies to help us recognize you and provide you with a good user experience when you browse this Site. We also use cookies and other similar technology to improve and enhance your online experience by remembering your log-in status and viewing preferences from a previous use of an online service, to honor your preferences and settings, to enable you to sign-in, to provide interest-based advertising, to combat fraud, to analyze how our products and services perform, and to fulfill other purposes described in this Privacy Policy. You may have set your consent for recurring and non-recurring cookies through the cookie banner on the homepage you are visiting, and you can change your consent and other preferences for cookies by following the guidelines there. For more information about our use of cookies and other tracking technologies, please see our Cookie Policy.Global Privacy Control and Opt-Out Preference Signals

Global Privacy Control and Opt-Out Preference Signals

We recognize user-initiated opt-out preference signals sent by your web browser, such as the global privacy control (“GPC”), as a valid request to opt-out of the sale and sharing of personal information processed on this website (i.e., through cookies and tracking technologies). For more information about GPC and how to implement it on your browser, please visit globalprivacycontrols.org. 

Do Not Track

Please note that certain web browsers may also transmit “do-not-track” signals to the websites with which the user communicates. Because there currently is no industry standard concerning what, if anything, websites should do when they receive such signals, we do not alter our practices when the website receives a “do-not-track” signal from a visitor’s browser.

Storage and Transfer of Information

All the information you provide, including your personal information, may be processed and stored, transferred or accessed by entities around the world. Specifically, the personal information that we collect from you may be transferred to, and stored at, a destination outside the United Kingdom (“UK”) or European Economic Area (“EEA”), including the United States. It may also be processed by staff operating outside the UK/EEA who work for us or for one of our Endeavor Group Companies or your information may be processed outside the UK/EEA by our suppliers (permitted third parties) who have entered into a processing agreement.

When we, or our permitted third parties transfer your information outside the UK/EEA, we or they will impose obligations on the recipients of that information to protect the information to the standard required in the UK/EEA or otherwise require the recipient to subscribe to international frameworks intended to provide secure data sharing. In the case of transfers to us, we will put in place appropriate safeguards to ensure that your information remains protected under the standards required by the sender’s jurisdiction.

Children

We are deeply committed to ensuring that children are safe online and, depending on the Service, have enacted extra privacy processes in order to better protect their privacy.

We take reasonable care to ensure that we do not knowingly collect, store, use, or process personal information from children who are under 13 years old. If you are a parent or guardian of a child who is under 13 years old and using our Services, please send us an email at dataprivacy@IMG.com to arrange for deletion of any personal information we may have collected about the child.

In the event we offer limited Services to children over 13, we take extra steps to protect their privacy including:

  • informing parents and guardians of the personal information we collect, store, use, and process from their child and explaining whether we share said information
  • obtaining parental and guardian consent to collect, use, and process their child’s data as required by law
  • limiting how we collect, store, use, and process children’s personal information
  • providing parents and guardians the means to access, restrict, and delete their child’s personal information

If you are a parent or guardian of a child who is 13-16 years old and using our Services, please send us an email at dataprivacy@IMG.com to opt in to the use of their personal information or request deletion of any personal information we may have collected about the child.

Privacy Rights

Depending on your jurisdiction you may have the following rights in connection to your data, including:

  • Access. You may have the right to access personal information we hold about you and ask us for other information such as purposes of processing, categories of personal information and recipients of the information.
  • Portability. You may have the right to request a copy of personal information about you and request that we transfer it to a third party (with certain exceptions).
  • Correction. You may be entitled to request correction of any personal information about you which is incomplete or inaccurate.
  • Erasure. In certain circumstances, you have the right to request deletion or erasure of the personal information we hold about you.
  • Restriction of processing to storage only. You may have the right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances.
  • Objection. Where we are processing personal information about you on the basis of legitimate interests, you may have the right to object to our processing of personal information about you.
  • Withdrawal of Consent. Where we rely on consent to process personal information about you, you have the right to withdraw this consent at any time by contacting us.
  • Appeal. Where applicable, you may have the right to appeal actions regarding your privacy request.
  • Complaint. You also have a right to lodge a complaint with a supervisory authority should you feel unsatisfied with our treatment of your personal information.

To exercise any of the above rights, please make a request online by using this webform.

You can also make a request via email at: dataprivacy@img.com

We will retain your personal information for as long as needed to provide you with services you have requested. We will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

Opting Out of the Sale of Your Personal Information

Sometimes we share your data with sponsors, vendors, Endeavor, and third-party advertising networks. These transfers, which are used to provide you with certain Services and/or to more effectively provide you with personalized Services (including advertising), can be deemed a sale under some data privacy laws.

If you haven’t already, you may opt-out of the sale or sharing of your browser-based personal information by visiting the cookie preference center on the cookie banner. Also see the Targeted Advertising section above as well as our Cookie Policy for additional information.

If you have given us additional information such as an email address, depending on your jurisdiction, you may have the right to opt out of the sale or sharing of your personal information by clicking on the Do Not Sell My Personal Information link on the homepage or calling +1-866-983-0571. You will be asked to provide certain information to us to exercise this option so we can verify your identity and locate your records with us.

Please note that your decision to opt out of the sale of your personal information may impact the availability and quality of some of the Services provided to you.

Notice to California Residents

Information Collection and Use

In the last 12 months, we collected the categories of personal information listed above in the Information We Collect and How We Use It chart.

We collect this information for the business and commercial purposes described in the chart and share this information with the categories of third parties described in the chart.

Disclosure of Personal Information

We may disclose your personal information to companies, organizations, and individuals inside and outside of our group as listed in the last column of the chart.

California Privacy Rights

As a California resident you have the following rights regarding personal information about you, subject to our ability to verify your request and certain other limitations:

  • Right to Know: You have the right to submit a verifiable request for copies of specific pieces of your personal information collected in the preceding 12 months or at your option since January 1, 2022;
  • Right to Delete: You have the right to submit a verifiable request for the deletion of personal information that you have provided to us. Certain information that we hold about you may not be deleted. We are not permitted to delete information that we need to operate our business, administer our employees, protect our legal obligations and rights, or to provide security for our employees, our systems and our company;
  • Right to Correct: You have the right to submit a verifiable request for the correction of inaccurate personal information maintained by us, taking into account the nature of the personal information and the purposes of processing the personal information;
  • Right to Opt Out of Sale and Sharing: You have the right to opt out of the sale of your personal information and the disclosure of your personal information for cross-context advertising;
  • Right to Limit Processing of Sensitive Personal Information: You have the right to tell us not to process sensitive personal information except for the purpose for which it was originally collected; and
  • Non-Discrimination: California law prohibits discrimination against you for exercising your privacy rights.

Exercise Your California Privacy Rights

To exercise your “Do-Not-Sell” right you can complete the online “Do-Not-Sell” webform linked at the bottom of the homepage of the site you are visiting.

Verification Process and Required Information

All requests must be verified. Some requests, including receiving a copy of your data or requests made by an agent claiming to be acting on your behalf, are subject to heightened requirements. If we cannot verify your identity based on the information provided, a request for a copy of your data shall be treated as a request for information and if we cannot verify your identity, a request to delete personal information may be treated as a request to opt out of the sale of personal information.

Authorized Agent

You may designate an authorized agent to make a request on your behalf. An authorized agent must have written documentation of their authority to act on your behalf, such as a Power of Attorney.

Security

We use a variety of administrative, physical, and technology solutions, including engaging with qualified cybersecurity companies, to protect your information from unauthorized access, loss, or misuse. Because there is always some risk in transmitting information over the internet and otherwise processing information, we cannot and do not guarantee or warrant the security of any information that you transmit on or through the Services or that we otherwise maintain.

Our Services, newsletters, email updates and other communications may, from time to time, contain links to and from the websites of others, including our partner networks, retail partners, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies.

Updates

Any updates we may make to our Privacy Policy will be posted on this page, and we may also provide a website notice of any material changes for a reasonable period of time. Please check back frequently to see any updates or changes to our Privacy Policy. If you do not agree or consent to these updates or changes, do not continue to use the Services.

Contact

Questions or comments regarding this Privacy Policy should be emailed to dataprivacy@IMG.com.